Law School Case Brief
Virgin Islands v. Knight - 989 F.2d 619 (3d Cir. 1993)
Fed. R. Crim. P. 12.2(a). Rule 12.2(a), provides that if a defendant intends to rely upon the defense of insanity at the time of the alleged offense, the defendant shall, within the time provided for the filing of pretrial motions or at such later time as the court may direct, notify the attorney for the government in writing of such intention and file a copy of such notice with the clerk. A defendant who fails to comply with this provision may not raise insanity as a defense at trial without demonstrating "cause" for the belated filing.
Knight was found guilty of voluntary manslaughter, possession of a firearm during the commission of a crime of violence, and possession of a firearm by a felon. The district court adjudged defendant a habitual offender and enhanced his sentence pursuant to 14 V.I. Code Ann. § 61 (1990).
Did the district court err in its judgment finding the defendant guilty?
The court held that the district court did not abuse its discretion by finding that Knight's explanation failed to establish cause for the late filing of his notice of intent to assert an insanity defense under Fed. R. Crim. P. 12.2(a). The district court's error in excluding an eyewitness' and an investigating officer's testimony that the firing of the gun was an accident did not prejudice defendant because the witness was permitted to describe fully the circumstances that led to his opinion. The court held that no evidence supported the conclusion that Knight reasonably believed he was in imminent danger of harm at the time of the assault. Thus, the district court properly declined to include a jury charge on excusable homicide. The court ruled that sentencing under the enhancement statute was proper.
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